Comments on misleading statements in the overview
In the overview, there are misleading or duplicitous statements (depending on your point of view) showing that the Government is following a policy that is not based on evidence but is, instead, politically expedient. This leads to a lack of public confidence in Government and can also be seen as an attack on the democratic process.
Here are some useful comments on individual statements made by DEFRA/Natural England:
1. Public Safety
“It is possible that badger control will be undertaken on parcels of land that are near to or adjoining public rights of way, roads and dwellings ….will be in possession of Police-issued Firearm Certificates and/or Shotgun Certificates and will have a responsibility to ensure that shooting is conducted in a safe direction with a suitable earth backstop. Although licensed badger control has been conducted since 2013, covering over fifty cull operations there have been no safety related incidents.”
During five years of badger culls, the police have been called out on numerous incidents where public safety has been compromised. There were incidents where some people known to be involved with the cull shot over people’s heads, intimidated people in their homes, slashed tyres, smashed windows. In addition, landowners in cull zones have been bullied into taking part.
2. Culling on your land
“All badger control and vaccination approved under licence will only take place on land with the landowner/occupier’s permission and land will only be entered onto if prior access has been agreed.”
On-the-ground evidence showed that cull operatives have been found trespassing on non-participating land and tenants have joined the cull without the landowner’s permission.
3. Location of the cull
“Natural England will not release maps nor other information revealing the positions of the boundaries for each cull area …. The culling of badgers is a sensitive issue and we are withholding this information, along with the names of those participating, on the basis that publication may cause unnecessary or unjustified distress or damage to the individuals or communities within those boundaries; and may increase the likelihood of groups opposed to the policy disrupting control activity.”
Evidence from cull zones shows that not knowing if ‘your’ badgers are targeted or if your neighbour is part of the cull leads to increased tension in both families and the community. The policy is even more divisive due to greater anxiety caused by uncertainty over where and when the culls are happening.
In two cases, Information Tribunals have ruled that those against the badger cull policy have the right to protest and lobby effectively.
To go further, the Aarhus Convention that came into law in 2001 specifically encourages public participation in environmental matters. That participation encompasses, as a central feature, public protest on matters of environmental concern. Whereas here, Government policy on an environmental issue is a matter of substantial debate and concern, the provision of environmental information, including information facilitating protest, is vitally important.
Increased protesting in the cull areas (or better directed protesting) is perfectly legitimate in a democratic society.
4. Impacts on your business or livelihood
“Culling will only take place over a short, set period during the year in each of the four licensed years.”
Evidence from the original cull zones in W Somerset and Glos suggests that at the end of four years, supplementary culling will continue for at least another five years and for a far longer period than six weeks. Evidence from cull zones also shows that badger persecution has increased exponentially as the result of the badger cull policy. Increasing numbers of badgers are killed illegally all year round. Since non-participants don’t know where or when the licenced culls are taking place, the result could be far more unrecorded and unreported illegal killing.
5. Ecological concerns
“Minimum badger numbers to be culled have been set to remove at least 70% of the true population. The 70% target is derived from the Randomised Badger Culling Trial (RBCT) where it was estimated that the culls achieved a mean of 70% control of the starting populations across the 10 areas, which resulted in disease reduction benefits for the cattle herds in those areas.
Natural England undertakes screening and Habitat Regulation Assessments on all UK and European designated sites that may be affected by the activities associated with a proposed badger control licence. This will determine the risk of any negative impacts towards the protected features of interest. Where there is deemed a potential risk, measures will be put in place to either avoid the site or mitigate any potential effects.”
Badger populations are notoriously difficult to calculate and budget restrictions have led to less effective population estimates being put in place. Obviously Inaccurate population estimates could result in local extinctions of badger populations.
Using the RBCT figure of 70% is meaningless since the badger culls have increasingly deviated from the methodology of the RBCT so the initial cost benefit analysis is useless and the expected meagre benefit of a 12 – 16% reduction in the increase of cases of bTB after NINE years of culling will not be achieved.
To date, despite a court order, Natural England has not released their Ecological Impact Assessment surveys. Due to budget restrictions leading to inadequate monitoring, it’s unlikely that any protection or monitoring is in place – unless publicly proved otherwise.
“Reasonable biosecurity measures are being, and for the duration of any licence will continue to be, implemented by participating farmers on their land to provide a strong protection against the spread of infection. This includes companies working with local veterinary practices to make sure cattle farmers are provided with adequate information on biosecurity measures they can take to protect their cattle from contact with wildlife if movement of badgers does occur.”
Freedom of Information requests have shown that participating farmers are implementing minimal to no biosecurity measures despite this Licence Requirement. In addition, breaches in testing and trading restrictions by farmers are regularly reported in both the local and farming press.
7. Badger vaccination
“The strategy includes a package of measures including cattle biosecurity, movement controls and badger vaccination in areas where TB is widespread.”
No measures have been put in place by Government to protect vaccinated badgers. As the cull rolls out to yet more areas, this effect will be exacerbated. In addition, the Government is not supporting any badger vaccination programmes in the High Risk Areas (such as the counties in this consultation) although badger vaccination is one of the ‘tools in the tool box’ available to the Government
8. Who carries out the ‘controlled’ (free) shooting and cage trapping?
“Those carrying out the work must have completed government-approved training (which includes competency based assessments on firearms handling, safety and marksmanship) to enable them to control badgers humanely and safely.”
The British Veterinary Authority (BVA has withdrawn support for ‘controlled’ (or free) shooting since the Independent Expert Panel ruled that it was inhumane. Some contractors have been found to use shotguns to free shoot badgers but this has not even been tested as a humane way to free shoot badgers. Thus the BVA does not support this methodology either. To reduce costs, monitoring has been subsequently reduced to a minimal amount so the inhumanness of free shooting is very much in doubt. Bear in mind that Natural England observations recorded 12.2% of badgers that were shot at but not retrieved whereas the percentage reported by the cull contractors is only 2.25%.
Cage trapping is only humane if carried out properly and evidence from cull zones shows that, in many cases, cages are set to kill in bad weather conditions and not regularly checked. At least one forgotten cage has been found and if it had contained a badger, it would have starved to death – how many more cages remain unfound and unreported?